Jonathan Maddison

Jonathan Maddison

Sutherland Asbill & Brennan LLP

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Taxpayer Wynne’s: Supreme Court Rules Maryland Personal Income Tax Violates Constitution

This morning the U.S. Supreme Court ruled that Maryland’s personal income tax regime is unconstitutional. By failing to provide a full credit to its residents for taxes paid to other states, Maryland unconstitutionally...more

5/19/2015 - Comptroller of the Treasury v Wynne Dormant Commerce Clause Income Taxes Non-Resident Income Taxes SCOTUS

Wynne Court Holds That Internal Consistency Lives, Applies to Taxation of Resident

A divided U.S. Supreme Court ruled that Maryland’s personal income tax regime is unconstitutional. Comptroller of the Treasury v. Wynne, 575 U.S. __ (2015). The Court affirmed the Maryland Court of Appeals in a 5-4 decision...more

5/19/2015 - Comptroller of the Treasury v Wynne Dormant Commerce Clause Income Taxes Non-Resident Income Taxes SCOTUS

Alas, the MTC Executive Committee Approves Its Transfer Pricing Program Design

After nearly a year of planning, the Multistate Tax Commission Executive Committee today approved the Arm’s-Length Adjustment Services Advisory Group (the Group) Final Program Design. The following six states have agreed to...more

5/8/2015 - Corporate Taxes Transfer Pricing Transfer Taxes

This is Not a Joke: Federal Court to Consider Quill and Comity

In the ongoing saga over Colorado’s use tax reporting laws in Direct Marketing Association v. Brohl (DMA), the U.S. Court of Appeals for the Tenth Circuit ordered a full briefing on the Comity Doctrine and the Commerce Clause...more

4/15/2015 - Comity Doctrine Commerce Clause Direct Mkting Association v Brohl Internet Retailers Retailers Sales & Use Tax State Taxes

If They Build It, Will They Come? ALAS Advisory Group Prepares Final Program Design to Present to MTC Executive Committee Amidst...

The Multistate Tax Commission’s (“MTC”) Arm’s-Length Adjustment Services Advisory Group (“the Group”) met via teleconference to continue working on the Final Program Design. States participating on the call were: Alabama,...more

4/8/2015 - Advisory Board Multistate Tax Commission

MTC Inches Closer to Developing Its Transfer Pricing Program

The Arm’s Length Adjustment Service Advisory Group (ALAS) of the Multistate Tax Commission (MTC) continued its transfer pricing effort with a teleconference today to discuss its training and implementation program. This...more

3/5/2015 - Multistate Tax Commission Transfer Pricing

All Nine Agree: U.S. Supreme Court Holds that the Tax Injunction Act Does Not Bar DMA’s Action in Federal Court

Yesterday the U.S. Supreme Court unanimously held in Direct Marketing Ass’n v. Brohl that the Tax Injunction Act (TIA) does not bar Direct Marketing Association’s federal lawsuit against Colorado.1 The TIA provides that...more

3/4/2015 - Direct Mkting Association v Brohl Reporting Requirements Sales & Use Tax SCOTUS Tax Injunction Act

MTC Launches Transfer Pricing Effort

On June 2, the Arm’s Length Advisory Group (the Group) of the Multistate Tax Commission (MTC) met in St. Louis, Missouri, to begin the process of developing a multistate arm’s length pricing adjustment service. States...more

6/3/2014 - Audits Multistate Tax Compact Transfer Pricing

MTC Executive Committee Advances Significant Part of UDITPA Rewrite

On Thursday, May 8, the Multistate Tax Commission’s (MTC) Executive Committee (Committee) met in Washington, DC. During the meeting the Committee voted to advance its amendments to the Multistate Tax Compact’s (Compact)...more

5/12/2014 - MTC Multistate Tax Compact Proposed Amendments UDITPA

Legal Alert: New York Tax Reform to Impact Captive Insurance Companies

In January, New York Governor Andrew Cuomo proposed broad corporate tax reform in his budget bill, which is currently winding its way through the legislature. The most significant proposal is a shift from a separate entity...more

2/28/2014 - Andrew Cuomo Captive Insurance Company Corporate Taxes State Taxes Tax Reform

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